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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

State v. Sinchak, 229 Conn. App. 38 (2024)

Citation
State v. Sinchak, 229 Conn. App. 38 (2024)
Parent Document
State v. Sinchak, 229 Conn. App. 38 (2024)
Jurisdiction
Connecticut (state)
Effective Date
2024-11-05

Full Text

2,400 chars
Alternatively, the state argues that the court’s order
       satisfies both prongs of Curcio. To satisfy the first prong
       of Curcio, the order or action must terminate a separate
       and distinct proceeding. State v. Curcio, supra, 191
       Conn. 31. The state argues that this prong is satisfied
       because the correction of an illegal sentence is separate
       and distinct from the matters determined in the defen-
       dant’s long final criminal judgment. The state’s argu-
       ment misses the mark. The question is not whether the
       defendant’s motion to correct is a separate and distinct
       proceeding from the underlying criminal judgment. The
       issue is whether the court’s granting of the motion ‘‘ter-
       minates’’ the proceeding. Clearly it does not. The pro-
       ceeding will not be terminated until the defendant is
       resentenced. Accordingly, the court’s decision does not
       satisfy the first prong of Curcio.
          To satisfy the second prong of Curcio, the rights of
       the appellant must be so concluded by the order that
       further proceedings cannot affect it. Id. ‘‘The second
       prong of the Curcio test focuses on the nature of the
       right involved. It requires the parties seeking to appeal
       to establish that the trial court’s order threatens the
       preservation of a right already secured to them and that
       that right will be irretrievably lost and the [parties]
       irreparably harmed unless they may immediately
       appeal. . . . Thus, a bald assertion that [the appellant]
       will be irreparably harmed if appellate review is delayed
       until final adjudication . . . is insufficient to make an
       otherwise interlocutory order a final judgment. One
       must make at least a colorable claim that some recog-
       nized statutory or constitutional right is at risk.’’ (Inter-
       nal quotation marks omitted.) Hartford Accident &
       Indemnity Co. v. Ace American Reinsurance Co., supra,
       279 Conn. 226. The state argues that the correction of
       an illegal sentence through resentencing deprives the
       state, victims, and survivors of their interests in the
       finality of the long final original judgment. We are not
       persuaded.
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